Nordlinger v. Hahn, 505 U.S. 1, 11 (1992)

Page:   Index   Previous  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  Next

Cite as: 505 U. S. 1 (1992)

Opinion of the Court

petitioner lived in an apartment in Los Angeles. This Court's prudential standing principles impose a "general prohibition on a litigant's raising another person's legal rights." Allen v. Wright, 468 U. S. 737, 751 (1984). See also Moose Lodge No. 107 v. Irvis, 407 U. S. 163, 166 (1972). Petitioner has not identified any obstacle preventing others who wish to travel or settle in California from asserting claims on their own behalf, nor has she shown any special relationship with those whose rights she seeks to assert, such that we might overlook this prudential limitation. Caplin & Drysdale, Chartered v. United States, 491 U. S. 617, 623, n. 3 (1989). Accordingly, petitioner may not assert the constitutional right to travel as a basis for heightened review.

B

The appropriate standard of review is whether the difference in treatment between newer and older owners rationally furthers a legitimate state interest. In general, the Equal Protection Clause is satisfied so long as there is a plausible policy reason for the classification, see United States Railroad Retirement Bd. v. Fritz, 449 U. S. 166, 174, 179 (1980), the legislative facts on which the classification is apparently based rationally may have been considered to be true by the governmental decisionmaker, see Minnesota v. Clover Leaf Creamery Co., 449 U. S. 456, 464 (1981), and the relationship of the classification to its goal is not so attenuated as to render the distinction arbitrary or irrational, see Cleburne v. Cleburne Living Center, Inc., 473 U. S., at 446. This standard is especially deferential in the context of classifications made by complex tax laws. "[I]n structuring internal taxation schemes 'the States have large leeway in making classifications and drawing lines which in their judgment produce reasonable systems of taxation.' " Williams v. Vermont, 472 U. S. 14, 22 (1985), quoting Lehnhausen v. Lake Shore Auto Parts Co., 410 U. S. 356, 359 (1973). See also Regan v. Taxation with Representation of Wash., 461

11

Page:   Index   Previous  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  Next

Last modified: October 4, 2007